Comment from Coinbase
CoinbaseSupportBusiness
Summary: Coinbase supports the proposed rulemaking but argues that the final rule must maintain a clear distinction between primary market activity (minting/redemption) and secondary market circulation. They advocate for a "gatekeeper" model that limits KYC and SAR obligations to direct customers to avoid technological unworkability, privacy risks, and the flooding of FinCEN with low-signal data.
Please see attached.